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International Taxation of Banking by ABRAHAMSON

International Taxation of Banking

By John Abrahamson
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Overview

Series on International Taxation, Volume Number 75.

About this book:

International Taxation of Banking introduces and analyses the international tax issues which relate to international banking activities. Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups.

What’s in this book:

The content of this book clearly identifies and explains the management of research and development and intangible property used in the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book examines such issues as the following:

  • taxation of dividends and branch profits derived from other countries;
  • transfer pricing and branch profit attribution;
  • taxation of global trading activities;
  • tax risk management;
  • provision of services and intangible property within multinational groups;
  • taxation treatment of research and development expenses;
  • availability of tax incentives such as patent box tax regimes;
  • swaps and other derivatives;
  • loan provisions and debt restructuring;
  • financial technology (FinTech);
  • group treasury, interest flows, and thin capitalisation;
  • tax havens and controlled foreign companies; and
  • taxation policy developments and trends.

Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail.

How this will help you:

The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will serve as an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Last Updated 02/19/2020
Product Line Kluwer Law International
ISBN 9789403510941
SKU 10071884-0002
Table of Contents

Preface

List of Abbreviations

CHAPTER 1 
Introduction

CHAPTER 2 
The Banking Regulatory Framework

CHAPTER 3 
Retail and Commercial Banking

CHAPTER 4 
Investment Banking

CHAPTER 5 
Introduction to International Tax

CHAPTER 6 
Tax Treaties

CHAPTER 7 
OECD BEPS Developments

CHAPTER 8 
Bank Parent Companies

CHAPTER 9 
Bank Branches

CHAPTER 10 
Other Bank Permanent Establishments

CHAPTER 11 
Representative Offices

CHAPTER 12 
Derivatives

CHAPTER 13 
Loan Provisions and Debt Restructuring

CHAPTER 14 
Value Added Tax: VAT

CHAPTER 15 
Bank Taxes: Financial Transaction Taxes and Bank Levies

CHAPTER 16 
Dividends and Profit Distributions

CHAPTER 17 
Group Treasury, Interest Flows and Thin Capitalisation

CHAPTER 18 
Intangible Property: IP

CHAPTER 19 
Tax Havens and Controlled Foreign Companies: CFCs

CHAPTER 20 
Introduction to Transfer Pricing

CHAPTER 21 
Transfer Pricing and Bank Branch Attribution

CHAPTER 22 
Transfer Pricing and Global Trading

CHAPTER 23 
Transfer Pricing and Loans

CHAPTER 24 
Transfer Pricing and Intangibles

CHAPTER 25 
Transfer Pricing and Services

CHAPTER 26 
Islamic Banking

CHAPTER 27
Green Banking

CHAPTER 28
Microfinance Banking

CHAPTER 29
Financial Technology: Fintech

CHAPTER 30 
Shadow Banking

CHAPTER 31 
Automatic Exchange of Information: CRS and FATCA

CHAPTER 32 
Taxation Policy Developments

CHAPTER 33 
General Conclusions

Case Studies

Case Study 1 
The Malaysia Branch: Permanent Establishments and Treaties

Case Study 2 
The Korean Bank Acquisition: Group Interest Deductions

Case Study 3 
Group Technology: Global Risk Management Cloud Software and Tax Treaties

Case Study 4 
The Italian Branch: Branch Attribution

Case Study 5 
Branch Profit Attribution: Corporate Loans and Global Trading

Case Study 6 
The Group Advertising Centre: Transfer Pricing Dispute

Appendix 
OECD Model Tax Convention 2017

Table of Cases

Table of Statutes and Directives

Table of Treaties and International Agreements

Index

Volumes